Assessing the Hidden Problem of Medical Waste Disposal

• By Burton J. Kunik
• Apr 13, 2010

A hidden waste management time bomb is ticking away, and health and safety professionals should understand its full dimensions: the disposal of medical waste, including used syringes, needles, lancets, and other sharps. The safe use, collection, and disposal of medical waste by health care professionals at hospitals and other health care facilities are closely regulated for self-evident reasons: Medical waste and sharps waste pose a substantial health risk to health care professionals, patients, waste workers, and the environment. It's important to understand that these same risks apply outside health care-related facilities, as well.

Companies in business sectors as diverse as transportation, industrial, hospitality, department stores, home care, and cleaning services have faced penalties for improper disposal of medical waste. In fact, facilities in more than 120 different non-health care industries have been issued citations for improper medical waste disposal. The health and safety implications are substantial, and proactive awareness of evolving regulation and disposal issues is essential.

OSHA Standards
In an attempt to protect workers throughout general industry, the Occupational Safety and Health Administration finalized its Bloodborne Pathogens Standard in 1991 and updated it in 2001. Individual states began to regulate the transport and disposal of medical waste in order to protect the public in the early 1990s, as well. Assisting a bleeding co-worker or picking up broken glass with blood on it requires a clearly thought-out program.

Today, in non-health care environments, employees such as first aid and spill cleanup responders, clinic nurses, and other workers understand the importance of following proper medical waste containment procedures. They are advised to wear personal protective equipment, place contaminated items in proper disposal bags, place contaminated sharp objects ("sharps") into sharps containers, and wash their hands.

However, such procedures in non-health care facilities often do not address the way medical waste and related cleanup materials are disposed following proper containment. Many facilities continue to toss bloody towels, glass, and even syringes into the trash. Some place sharps into containers but then throw those containers into the trash. It is estimated more than 3 billion syringes generated outside of health care are discarded into the regular trash annually. This practice exposes waste workers, communities, the public, and the environment and may be violating federal, state, or local guidelines or regulations on sharps disposal.

It is impossible to estimate the volume and types of sharps, such as bloody glass and box cutters, and non-sharps spill cleanup materials that are tossed into the trash every year. Hospitals and hazmat cleanup teams do not throw their bloody waste into the trash, so why do non-health care facilities do so?

Employer Obligation
The simple fact is that OSHA's standard requires employers to determine whether any of their employees performs tasks that could expose him or her to blood or other potentially infectious materials (OPIM), such as those involved in the cleanup and disposal of a biohazard spill. If there is such exposure, the employer must establish a Bloodborne Pathogens Exposure Control Plan detailing how these at-risk employees will be protected while performing such tasks. All facilities in general industry that have one or more employees with occupational exposure to bloodborne pathogens are covered under the OSHA standard. Facility managers often think they are not covered by the standard if they are not health care organizations, but OSHA regulations make it clear this simply is not true.

Employees in non-health care settings with occupational exposure would include those who are expected to perform the following tasks as a part of their jobs:

• Provide first aid or medical care to customers or fellow employees
• Handle sharps, such as discarded hypodermic needles, broken glass with blood on it, or bloody knives
• Clean up a blood spill from a cut or puncture wound
• Clean up a body fluid spill on the floor after a pregnant customer's "water" breaks
• Handle trash containing bloody items from a clean up kit

Employers must consider exposure from the point of notification of a situation through proper disposal of the resulting cleanup materials. If any step is left out, an exposure incident could occur -- and exposure can involve not only employees, but also customers or other visitors to a facility. Such exposure can run more $3,000 per exposed person for testing and initial treatment alone. The cost to a company's reputation because of the legal risk from exposure is incalculable.

Compliance Process
To comply with OSHA and state regulations, businesses with the potential for having a medical waste exposure incident occur must have a system and plan for the safe and compliant cleanup, containment, and disposal of the resulting waste. The facility Exposure Control Plan and risk management procedures should include the following steps:

• Supply PPE appropriate for the type and size of a waste cleanup. The inclusion of gloves, gown, mask, shield, hair cover, and shoe covers will allow for proper protection for any spill.
• Contain spill exposure. For example, absorbents are one of the best methods for the containment of body fluid spills and preventing the fluids from splashing during handling. Of course, contaminated absorption material must still be disposed of safely.
• Contain sharps exposure. In addition to syringes discovered in company restrooms or parking lots, blood spills in the non-health care environment often include broken glass, bloody box cutter blades, or other contaminated sharps. Having a container specifically designed to receive and retain those sharps safely can mean the difference between an exposure incident and proper cleanup.
• Clean and disinfect the surface. To assure complete decontamination, a surface must be cleaned prior to disinfection. Use a product that is designated as both cleaner and disinfectant and make sure the disinfectant is EPA-registered in all states in which it will be used.
• Dispose of the waste. This is the step too many facility plans ignore. Once the waste material is contained, the facility must use safe and compliant disposal methods according to state and local regulations. Throwing sharps containers, red bags, and spill cleanup materials into the trash sends up a red flag to commercial or municipal trash collectors because they are not allowed to take this waste.

Traditional spill cleanup kits typically stop short of providing the final disposal step. One effective disposal option that is recommended by federal agencies such as EPA and many state regulators is disposal by mail. A disposal by mail system consists of a government-approved medical waste or sharps container and a postage-prepaid return shipping box. Full containers are sent via the U.S. Postal Service to a permitted treatment facility for documentation, weighing, destruction of each package and its contents, and subsequent confirmation. Disposal by mail companies can help to determine specific practice needs based on types of exposures, state regulations, and other factors.

The greatest advantage they offer is convenience. There are no calls for pickups, no interruptions of facility operations, no monthly fees, no contracts, no keeping up with waste manifests because they are maintained by the end processor, and no extra costs beyond the basic system components. It is an effective solution in any state and protects employees and customers, making the problem of medical waste disposal one less thing any company needs to worry about.